Classification of the Company as Corporation for Tax Purposes. (a) The Company has made an election to cause it to be classified as an association that is taxable as a corporation and, subject to clause (d) below, shall maintain such classification.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (TCW Direct Lending VII LLC), Limited Liability Company Agreement (TCW Direct Lending VII LLC), Limited Liability Company Agreement (TCW Direct Lending VII LLC)
Classification of the Company as Corporation for Tax Purposes. (a) The Company has made intends to make an election as of the Initial Drawdown Date to cause it to be classified as an association that is taxable as a corporation and, subject to clause (d) below, and shall maintain such classification.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Goldman Sachs Private Middle Market Credit LLC), Limited Liability Company Agreement, Limited Liability Company Agreement (Goldman Sachs Private Middle Market Credit LLC)
Classification of the Company as Corporation for Tax Purposes. (a) The Company has made intends to make an election to cause it to be classified as an association that is taxable as a corporation and, subject to clause (d) below, shall maintain such classification.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (TCW Spirit Direct Lending LLC), Limited Liability Company Agreement (TCW Star Direct Lending LLC), Limited Liability Company Agreement (TCW Direct Lending VIII LLC)
Classification of the Company as Corporation for Tax Purposes. (ai) The Company has made intends to file an election with the Internal Revenue Service to cause it to be classified as an association that is taxable as a corporation and, subject for U.S. federal income tax purposes on or prior to clause (d) below, shall maintain such classificationthe date on which the Company has more than one Member.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (LGAM Private Credit LLC), Limited Liability Company Agreement (North Haven Private Income Fund a LLC), Liability Company Agreement (North Haven Private Income Fund LLC)
Classification of the Company as Corporation for Tax Purposes. (a) The Company has made or will make an initial entity election to cause it to be classified as an association that is taxable as a corporation and, subject for U.S. federal income tax purposes effective on or prior to clause (d) below, the Initial Drawdown Date and shall maintain such classification.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (West Bay BDC LLC), Limited Liability Company Agreement (West Bay BDC LLC), Limited Liability Company Agreement (West Bay BDC LLC)
Classification of the Company as Corporation for Tax Purposes. (a) The Company has made intends to make an election as of the Initial Drawdown Date to cause it to be classified as an association that is taxable as a corporation and, subject to clause (d) below, for U.S. federal income tax purposes and shall maintain such classification.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Phillip Street Middle Market Lending Fund LLC), Limited Liability Company Agreement (Goldman Sachs Private Middle Market Credit II LLC), Limited Liability Company Agreement (Goldman Sachs Private Middle Market Credit II LLC)
Classification of the Company as Corporation for Tax Purposes. (ai) The Company has made intends to file an election with the Internal Revenue Service to cause it to be classified as an association that is taxable as a corporation and, subject to clause (d) below, shall maintain such classificationfor U.S. federal income tax purposes as of the Initial Drawdown Date.
Appears in 1 contract
Samples: Limited Liability Company Agreement (T Series Middle Market Loan Fund LLC)
Classification of the Company as Corporation for Tax Purposes. (a) The Company has made intends to make an election to cause it to be classified as an association that is taxable as a corporation and, subject to clause (d) below, for U.S. federal income tax purposes and shall maintain such classification.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Oaktree Gardens OLP, LLC)
